ML19331B821

Responds to NRC 800604 Ltr Re Violation Noted in IE Insp Rept 50-352/80-07.Corrective Actions:Crevices Involved Have Been Thoroughly Flushed W/Cleaner Until No Further Penetrant Seeped from Open Crevices

ML19331B821
Person / Time
Site:	Limerick
Issue date:	07/03/1980
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19331B820	List: ML19331B821
References
NUDOCS 8008130267
Download: ML19331B821 (3)

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PHILADELPHIA ELECTRIC COMPANY g 2301 MARKET STHEET P.O. BOX 8699 PHILADELPHIA. PA.19101

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JOHN S. KEMPER VIC E#R ESID ENT EN'Lemaamsme ano massancM e sa g Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcernent, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region Letter dated June 4,1980 RE: Site and Office Inspection of April 29-30, 1980 Inspection Report No. 50-352/80-07 Limerick Generating Station, Units 1 and 2 File: QUAL 1-2-2 (352/80-07)

Dear Mr. Grier:

In response to the subject letter regarding items identified during the st.bject inspection of construction activities authorized by NRC License Nos.

CPPR-106 and -107, we transmit herewith the following:

Attr.chment I - Response to Appendix A Should you have any questions e oncerning these items, we would be pleased to discuss them with you.

Sincerely,

. ? /Cf J..S. Kemper JMC/ramk l Attachment j l

800813o 24>7

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y, ATTACHMENT I RESPONSE TO APPENDIX A Item of Noncompliance Infraction Appendix B, of 10CFR50, Criterion V, states, in part: " Activities affecting quality shall be prescribed by documented instructions, procedures,...and shall be accomplished in accordance with these instructions...."

The Limerick PSAR,-Appendix D, Quality Assurance Program, paragraph D.4.13 states,.in part: "...The vendor shall have written procedures governing the control and use of... inspection procedures...."

-General Electric purchase order, dated March 13, 1980 to Reactor Controls states, in part: " Seller to perform the modification rework on the Limerick I shroud...in accordance with the specifica-tion entitled " Technical Scope cf Limerick Units 1& 2... dated March 1, 1980, "which states that, "All welding cleaning, NDE and Quality requirements shall be per GE document 22A4202, Rev. 5."

General Electric document 22A4202 states; in part: " Measures shall be taken to prevent entrapment of penetrant materials in crevices."

Contrary to the above, on April 29, 1980, Reactor Controls had performed grinding and liquid penetrant examinations on fillet welds in the shroud without having control procedures and as a result liquid penetrant materials were allowed to penetrate into crevices.

Response to Infraction .

The crevices involved, between the LPCI Wacer Box top plate and the Unit 1 RPV Shroud wall, and between seismic blocks and the LPCI top plate, have been thoroughly flushed with an approved cleaner until noEfurther penetrant seeped from the open crevices.

In the future all open crevices will be securely sealed before performing a penetrant examination which shall be performed in ,

accordance with GE Field Disposition Instruction 52/73030, paragraph " Welding and Examination" -

step #3, and 22A4202, j Rev. 3, paragraph 12.1.3.1.

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'All personnel that may be doing penetrant examinations have been trained in the implementation of GE Field Disposit' ion Instruction 52/73030, paragraph - " Welding and Examination" - step #3, and 22A4202, Rev. 3, paragraph 12.1.3.1. These training sessions have been documented.

In the process of correcting the situation identified in this infraction, PECO has become aware of a discrepancy in the General Electric purchase order and related documentation, The GE purchase order invokes GE document 22A4202, Rev. 5 as well as Field Disposition Instructions (FDI's) 52/73030 and 30/73030. These FDI's reference GE document 22A4202, Rev. 3. To correct this conflict GE has agreed to amend their purchase order to indicate that the latest revision of 22A4202 is applicable only when a specific revision number is not noted in other referenced documents.

(a comparision between Rev.'s 3 and 5 of 22A4202, paragraph 12,1.3.1 shows that the paragraph is identical in both rev.'s.) This corrective action to eliminate the conflict within the GE documents will be complete by August 31, 1980. l I

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